By: Calli Schlientz, Director of Compliance
ITAR Compliance Checklist
If your organization engages in exporting or importing defense articles, or furnishing defense services to foreign entities, you must achieve ITAR compliance.
The U.S. International Traffic in Arms Regulation protects national security and foreign policy interests by preventing the unauthorized transfer of sensitive technology. ITAR specifically controls the exporting and importing of defense items (called munitions). These can include technology like encryption algorithms and computer software. They also include bombs, guns, ships, tanks, and airplanes.
The actions of ITAR abusers can harm national security. Therefore, violations may result in severe civil and criminal penalties. Violators may also damage their brand reputations and lose licenses to export and import.
A Guide for Your ITAR Compliance Journey
To manage your IT environment to achieve and maintain ITRA compliance, the program you develop should focus on monitoring and controlling regulated import and export activities. To guide you on this mission, here’s a checklist covering the necessary high-level activities:
- Establish an ITAR-specific compliance program—Understand how your business works to determine your risk areas. Many companies that don’t engage in manufacturing, exporting, or brokering must still maintain a compliance program to reduce the risk of violations.
- Know your obligations—See the U.S. Munitions List to determine if your organization is subject to ITAR and what ITAR requires. This includes registration and obtaining approvals before engaging in export, import, and brokering activities.
- Know your customers—This includes their intended use of the defense articles and services. Screen all parties involved in transactions. Also know which countries the U.S. government has denied approvals for receiving defense articles and services.
- Document the licensing procedures—Keep detailed records of all defense-related exports and imports. This includes the registration of your corporate controller and the licensing of items and services
- Categorize your munitions items—The munitions list spans 21 categories classified into 16 sections. The classification determines restrictions, exemptions, and licensing requirements.
- Control access—Identify the access privileges of your internal users based on their job roles. Implement robust authentication methods.
- Manage risks—Conduct a thorough assessment to determine the risks of unauthorized transfer of sensitive technologies. Then implement a plan to close any security gaps.
- Coordinate incident response—Establish a plan for mitigating, reporting, and investigating data breaches.
- Audit regularly—Verify your exports and imports of ITAR-controlled items. Create a system for investigating discrepancies.
- Train your employees—Invest in staff training for ITAR and your related infrastructure to foster a culture of compliance across your enterprise.
- Encrypt sensitive data—Use encryption to ensure only authorized recipients can decrypt data.
- Control data sharing—Use technology to prevent the sharing of ITAR data with unauthorized individuals.
After working through this checklist, review the ITAR provisions and complete your registration with the Directorate of Defense Trade Control (DDTC). As part of this process, determine the legal authority over your product. A handy tool to work your way through the compliance process is the ITAR Risk Matrix. It outlines several elements to consider when building your program and how to assess your risk.
How DataBank Supports ITAR Customers
DataBank equips its colocation data center facilities to fully support ITAR compliance for our customers. We implement the required security protocols and demonstrate our capabilities through annual third-party audits.
Customers trust our compliance experts—including a dedicated CISO—to support their needs. Our customers also rely on our managed services security program that ensures compliance with ITAR. Our relevant certifications include a FedRAMP Authority to Operate (ATO) as well as SSAE 18 SOC 1 Type 2 and SOC 2 Type 2.
To learn more about how DataBank data centers can help your organization comply with ITAR and other regulations, contact DataBank today. In addition to achieving compliance, you can safeguard personal information and build confidence among your customers.
Data Center Growth and Downtown Office Vacancy
The commercial real estate market is facing unprecedented challenges today, leading to historically low demand and high vacancy rates. This scenario is driven by high interest rates, post-pandemic remote work arrangements, and lingering concerns about the economy. It’s all contributed to an oversupply of commercial properties, leaving owners and landlords unclear how to proceed for the foreseeable future.
Where some see challenges, others see opportunities. During this downturn, there has been growing interest in reusing these commercial properties for many different purposes, possibly converting them into modern data centers. There have already been several high-profile examples of the commercial-property-to-data-center trend:
In addition to these examples, there are many more where shopping malls, retail properties, warehouses, and other buildings otherwise difficult to rent have been converted into much-needed data centers.
Many Clear Advantages
At first glance, this trend seems to be a good fit. First, there’s demand: Data centers simply can’t be built fast enough as operators continue to do all they can to keep pace with AI-driven needs for computing and cloud services.
Then there’s the happy coincidence that so many vacant commercial properties are located in urban areas that have access to key infrastructure such as fiber networks, power grids, and, in rare circumstances, direct connections to interconnection hubs, which can make them especially well-suited for data center conversions.
There are other advantages, too. Office buildings often meet specific zoning requirements for data center operations, and many offer enough square footage to accommodate so many racks of servers and other hardware.
Potential Bumps in the Road
While converting commercial properties to data centers may seem to be a no-brainer, there are other factors to consider that may make the process more challenging than it may seem.
For example, many commercial properties may not be initially equipped to deliver the power and cooling today’s data centers require, even if they’re located in cities or urban areas. Additionally, this could put pressure on operators to focus on renewable energy sources, energy efficiency, and sustainability. Retrofitting some commercial real estate to handle these increased power loads and cooling systems can be extremely expensive, and in many cases, prohibitively so.
Data centers tend to require open floor plans, high ceilings for adequate air flow, reinforced structures to support equipment that gets heavier by the day, and increasingly, design flexibility and innovation to meet for new colocation customers’ demands. In many cases, these elements just might not be possible when attempting to convert traditional office buildings into modern data centers.
Remember the old saying about real estate and that it’s all about location, location, location? In this case, location may be either an advantage or a disadvantage. It can be an advantage if certain workloads are not connectivity- or latency sensitive and can be housed in remote high-powered locations. Alternatively, it can be a disadvantage if the property doesn’t have easy access to vital infrastructure; for example, if buildings don’t have access to high-speed network connections, carriers, and telecommunication network hubs, they may be hard-pressed to deliver the low latency and high performance their applications and workloads require.
Then there’s the talent component. It’s important to remember that data centers rely on so many talented employees to staff and manage each facility. Additionally, colocation data centers need to be readily accessible to their customers’ employees. Commuting into the city, parking, and getting into — and out of — each facility may present challenges not seen with more suburban data centers or campuses.
Finally, as much as high vacancy rates may have landlords offering deep discounts, downtown office space is still expensive – and more than some data centers may want to pay. In this case, the opportunity cost to convert commercial buildings into data centers could be considered a pro as well as a con.
The Right Answer is Still Emerging
In many ways, the transformation of underutilized commercial real estate into data centers seems to be promising solution to the challenges facing both sectors in 2024, although it requires careful consideration of the economic, technical, and environmental factors involved.
For some, the perfect opportunity may exist, enabling them to quickly and cost-effectively transform a vacant office building into their next jewel-in-the-crown data center. Others may find too much risk and may need to fall back to more traditional development strategies. It is a unique time but unfortunately, there are no easy answers.
By Dan Fuentes, SVP Enterprise Sales
The flagship computing cluster deployed by the university’s Division of Research in the IAD2 data center is known internally as Zaratan. The compute resources are available to any researcher on campus that has High-Performance Computing needs. Research spans the fields of astronomy, physics, biology, social sciences, and Artificial Intelligence. Scientists also used the cluster to analyze data from the Deep Impact project—where NASA crashed a satellite into a comet to determine its internal composition.
BUSINESS PROBLEM
UMD started deploying HPC clusters at the turn of the Century on Campus. The cabinets were set up to support 5kW per cabinets. The reliability of the power, along with the lack of redundancy, was causing great inefficiencies with their researchers. If the Data Center or a specific cabinet lost power off-hours the researchers would have to stop leveraging the system until support could arrive in person to fix the problem. In addition, the cooling requirements continued to rise in demand. Higher Densities were necessary. The University quickly acknowledged that a 24/7 staffed site, with the potential to deliver Liquid Cooling was a necessity.
DATABANK SOLUTION
DataBank was able to meet this demand in our IAD2 (McLean Data Center). We worked vigorously with UMD to fully understand its specific requirements. We ultimately redesigned the first floor of our Data Center to enable Liquid Cooling, and fully managed the implementation of the following:
- (392) s/f Raised floor to accommodate 20 cabinets
- 10 water-cooled cabinets for servers that handle research processing.
- 10 air-cooled cabinets for networking gear and storage devices.
- (350kW)+ power depending on the number and type of simulations researchers need to run at the same time.
- 3 dedicated 3-phase A/B/C power distribution units that provide power redundancy to the cabinets with forty 415-volt/60-amp/3-Phase/560c6W power whips.
- (2) CoolIT Chx750 coolant distribution units (CDUs) with redundant A/B power for liquid cooling.
- Aquatherm cooling loop, featuring polypropylene piping.
- Because CDUs provide most of the cooling, it takes less than one computer room air handler (CRAH) to cool the infrastructure.
BUSINESS RESULT
UMD can now:
- Feel confident in eliminating power outages because of the fully resilient DataBank Data Center
- Lean on our 24/7 support, and be confident that any issues will be addressed immediately
- Run at much higher densities than ever before, enabling 64-core CPUs in Zaratan servers to perform faster because of liquid cooling, which translates into
- much better experiences and efficient engagements for its Researchers
- Avoid the expense of staffing a Data Center since DataBank provides all DC Infrastructure
- Repurpose its on-campus Data Center
- Achieve its green initiatives.
The Zaratan High-Performance Computing infrastructure, powered and cooled by the DataBank IAD2 data center is allowing researchers at the University of Maryland to explore complex problems, engage in competitive research opportunities, and discover novel research applications.
For more information on the Zaratan/DataBank environment, please click here.